Thinking outside the sphere

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Report on Analysis of Proposed Cell

Tower at Newton Road, Woodbridge

Connecticut

David Maxson, WCP

Note: Color Document – Please rely on electronic version or original color prints.

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Table of Contents

Introduction ..................................................................................................................................... 3

Coverage .......................................................................................................................................... 3

Alternative Tower of Lesser Impact but Equivalent Coverage ........................................................ 4

Conclusion – WNNET’s Alternative Locations on Meetinghouse Lane is a Viable Coverage

Alternative with Lesser Impact ........................................................................................................ 5

Exhibit A – Isotrope Coverage Analysis ........................................................................................... 7

Exhibit B – Curriculum Vitae of David P. Maxson, WCP ................................................................ 13

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Introduction

This report reviews the evidence provided by the applicant Cellco Partnership d/b/a

Verizon Wireless (Cellco) for approval to develop a cell tower at Newton Road, in

Woodbridge. This report also relies on new material produced by the author, David P.

Maxson, WCP, to refine the record. Mr. Maxson’s curriculum vitae is Exhibit B.

Coverage

Applicant’s data for the 1900 and 850 MHz Bands Are Irrelevant

Applicant’s data for the 1900 and 850 MHz bands re irrelevant because they are not currently

operational in Woodbridge. The coverage maps in Attachment 6 of the application reveal

that 1900 MHz and 850 MHz service is not offered from cell sites in and around most of

Woodbridge at present. Verizon sites labeled Woodbridge South, Woodbridge East,

Westville West, Bethany, Ansonia East, and Hamden are not presently offering 850 and

1900 MHz services. Therefore, any showing of coverage in these bands from the proposed

site is uninformative without first populating existing sites with these services.

Applicant’s Asserted Coverage Need Is Driven by the Proposed Tower –

WNNET’s Alternative Meets the True Need

The applicant’s coverage objective has been circularly defined by using coverage from the

selected location as the definition of the coverage need. Here are two excerpts from the

application narrative:

“The proposed Woodbridge North 2 facility would provide wireless service to a 1.2-mile

portion of Rt 63; a 0.1-mile portion of Rt 67; a 1.9-mile portion of Rt 114;…” (p9

application)

“These wireless service deficiencies exist particularly along Route 63 (Amity Road), Route

67 (Seymour Road), and Route 114 (Center Road) and in the area surrounding the

Property, including the Amity Regional High School and the Alice Newton Street Memorial

Park.” (p6 application).

In contrast, the original search ring was in northern Woodbridge:

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“Coverage enhancement along Rt 63, Rt 67, and surrounding residences.” (Search Area

Request Form (“SARF”))

The proposed facility fails to address half of the original objective because it provides no

material improvement to service to and along Rt 67 (it only “enhances” about 500 feet

(0.1 mi) of Rt 67 according to the above testimony).

In summary, Cellco was planning to address a small service area in the vicinity of Routes

63 and 67, but got sidetracked to the proposed site, which fails the Rt 67 objective.

Instead, because the proposed location is so far south, the description of need crept in

the direction of the High School, a recreational property and (not mentioned) the town-

center services at Meetinghouse Lane. Abandoning the original objective, these targets

for improved service, along with 1.9 miles of Rt 114, were opportunistically added to

support rationalizing the proposal. If these service areas had originally been the objective

of the SARF, the applicant would undoubtedly have looked toward the town properties

near Rt 114, which we propose herein.

Alternative Tower of Lesser Impact but Equivalent Coverage

Assuming the coverage from the proposed facility is the metric for alternatives (which is

discredited by the fact that the proposed facility is far south of the original objective), we

identify two alternative locations as examples that could be considered. They are on Town

properties.

First, Isotrope modeled coverage from the location of the existing public safety radio

tower (monopole) at 4 Meetinghouse Lane. The existing radio tower is about 120 feet tall,

so 120 feet was the starting height for coverage modeling. Note that the tower was built

for relatively low-profile two-way radio antennas and may not have the necessary

structural capacity to support cellular antennas without reinforcement or replacement.

Still, the fact that this tower already exists makes it a sensible location for upgrading the

tower structure to provide commercial services as well as public safety communications.

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Second, we identified a location at 15 Meetinghouse Lane (town DPW parcel or the one

adjacent to it – 149 Center Road) where the Town has indicated that a tower would be

acceptable. It is set well back from the road and is well away from residences.

We performed detailed modeling of the coverage from the 4 Meetinghouse Lane tower

site. We found the differences in coverage between this location and the proposed

location were minimal (See attached Figures 2 and 3 in Exhibit A). Also, comparing two

heights at 4 Meetinghouse Lane, differences in the coverage footprints between 120 and

150 feet were not substantial, which allows for limiting tower height to that which is

needed to accommodate several wireless carriers. In this case, the coverage from 4

Meetinghouse Lane is competitive with that from the proposed location. The differences

are shown in the table below.

SITE/HEIGHT Increase in coverage relative to existing

>-95 dBm

Area (square miles) Streets (miles)

Proposed 100 ft 2.05 11

4 Meetinghouse 120 ft 1.83 11

4 Meetinghouse 150 ft 2.23 11 Table 1 - Table of Comparative Metrics

Exhibit A contains five figures containing coverage maps produced on the software

program EDX SignalPro, a standard computer modeling platform Isotrope utilizes in

analyzing coverage for wireless communications facilities. Figure 1 shows our version of

Verizon’s existing 700 MHz coverage based on available information. Figure 2 shows

existing plus proposed. Figure 3 shows existing plus the alternative at 120 feet at 4

Meetinghouse Lane. Figure 4 shows existing plus the alternative at 150 feet at 4

Meetinghouse Lane. Coverage from 140 feet at the 15 Meetinghouse Lane site is shown

in Figure 5. the height was chosen to complement the coverage obtained from the other

configurations above.

Conclusion – WNNET’s Alternative Locations on Meetinghouse Lane

is a Viable Coverage Alternative with Lesser Impact

Of particular note is the fact that both Verizon’s proposed facility and WNNET’s

alternative site at 4 Meetinghouse Lane do not reach Route 67 and the portion of Route

63 which lies north of Route 67.

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While both Verizon’s proposed tower location and WNNET’s alternative suffer the same

conflict with the original SARF (the search ring), as discussed above, WNNET’s alternative

provides an apples-to-apple comparison with the Application. More importantly,

WNNET’s proposed alternative location provides competitive coverage with

significantly less impact to residential neighborhoods.

David Maxson, WCP

August 20, 2021

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Exhibit A – Isotrope Coverage Analysis

Figure 1 - Existing Verizon 700 MHz Coverage ................................................................................ 8

Figure 2 - Existing plus Proposed ..................................................................................................... 9

Figure 3 - Existing plus 4 Meetinghouse at 120 feet ..................................................................... 10

Figure 4 - Existing plus 4 Meetinghouse at 150 feet ..................................................................... 11

Figure 5 - Existing plus 15 Meetinghouse at 140 feet ................................................................... 12

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Figure 1 - Existing Verizon 700 MHz Coverage

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Figure 2 - Existing plus Proposed

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Figure 3 - Existing plus 4 Meetinghouse at 120 feet

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Figure 4 - Existing plus 4 Meetinghouse at 150 feet

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Figure 5 - Existing plus 15 Meetinghouse at 140 feet

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Exhibit B – Curriculum Vitae of David P. Maxson, WCP

David P. Maxson, WCP

Curriculum Vitae

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Isotrope, LLC, Medfield, Massachusetts, 1982*-present Founder, CEO

*Note – Isotrope, LLC continues a prior business operated by David Maxson since 1982. Isotrope was formed in 2009.

Charles River Broadcasting Company, Waltham, Massachusetts, 1978-1998. Vice President, Director of Engineering and Technical Operations

Affiliations

Certified IEEE Wireless Communications Professional®, demonstrating “a thorough understanding of different key technologies in the wireless arena.”

Member of National Radio Systems Committee, 1998-present.

Digital Radio Broadcasting Subcommittee, IBOC Standards Development Working Group

Chairman: Location Based Services Working Group, 2012-2015

RBDS Subcommittee, AM/FM Analog Broadcasting Subcommittee

Member of International Committee on Electromagnetic Safety (“ICES”) 2016 – present

Certificate of appreciation for service on the Editorial Working Group for C95.1-2019 IEEE Standard for Safety Levels with Respect to Human Exposure to Electric, Magnetic, and Electromagnetic Fields, 0 Hz to 300 GHz.

Member of the Committee on Man and Radiation (“COMAR”) 2019 – present

Electromagnetic safety policy and information

Charter Member of Wireless Infrastructure Association’s DAS Forum (the small-cell group) 2008

Corresponding Member: IEEE-USA Committee on Communications Policy, 2012 to present

Senior Member, IEEE; Certified Broadcast Radio Engineer, Society of Broadcast Engineers; FCC General Class Radiotelephone License with Radar Endorsement, Massachusetts Licensed Construction Supervisor #CS073481.

Project Highlights

Subject Matter Expert and trackside network design lead for Caltrain trackside broadband project, 2019 to present

Subject Matter Expert and Design and Construction Manager for Trackside Facilities – Amtrak wireless data trackside network, 2014-2018

Expert testimony, Strayton v. Martha’s Vineyard Commission, New Cingular Wireless, MVWiFi, et al, Massachusetts Superior Court, C.S. No. 1874 CV0008, 2020.

Subject Matter Expert and Project Manager - Utah Broadband Project’s Wireless Broadband Surveys: developed test plan and conducted 7000-mile drive tests of wireless broadband service availability across Utah in 2011 and 2013.

Project Reviewer - NTIA Broadband Technology Opportunities Program and USDA Rural Utilities Service Broadband Initiatives Program – American Recovery and Reinvestment Act, 2009.

Project Director and Engineer, PAVE PAWS Radar Environmental Emissions Modeling and Survey, for PAVE PAWS Public Health Steering Group, 2004-2005 (results peer reviewed by Nat’l Academies of Science)

Massachusetts Department of Public Health, follow-up survey of specific locations not evaluated in PAVE PAWS study; 2007-2008

US House of Representatives Telecom Subcommittee, Testimony on RF interference study, February 2000.

a) Radio communications facility and network design and construction

b) Safety planning and evaluation of communications facilities, safety protocol development

c) Research and development on digital media initiatives d) Evaluation of radio frequency facilities for compliance with technical and regulatory standards

e) Radio frequency interference remediation f) Expert consultation in radio and digital communications litigation

g) Municipal guidance in wireless planning and regulation

David P. Maxson, WCP

Curriculum Vitae

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Wireless facility evaluation and planning consultant to the Cape Cod Commission as well as to over a hundred municipalities in New England and beyond, 1999 to present. Performed more than 500 wireless facility reviews

Appointed member of Massachusetts Department of Public Health ad hoc committee on revisions to electromagnetic energy safety regulations 105 CMR §122, 1997.

Selected Publications

Peer-reviewed paper: FM 8th Harmonic Interference to Wireless Facility Not Radiated by the FM Station: A Case Study, Proceedings of the National Association of Broadcasters Broadcast Engineering Conference (“NAB-BEC”), 2020.

Peer-reviewed paper, co-author: IEEE Committee on Man and Radiation—COMAR Technical Information Statement: Health and Safety Issues Concerning Exposure of the General Public to Electromagnetic Energy from 5G Wireless Communications Networks, Health Physics: August 2020 - Volume 119 - Issue 2 - p 236-246

Author, Your Mileage May Be Different – Reflections on Megabits per Second and Miles per Day [on a statewide drive test of broadband data connectivity in Utah], Above Ground Level Magazine, December 2011.

Principal Author, A Tractable Approach to Defining and Measuring IBOC Signals against the RF Masks, Annex 1, NRSC Guideline -G201: NRSC-5 RF Mask Compliance: Measurement Methods and Practice, 2010, reaffirmed 2016

Peer-reviewed paper: New Kinds of Interference in the FM Band: 2 Case Studies of Stuff You Didn’t Know, NAB-BEC, 2016

Author, The IBOC Handbook— Understanding HD Radio Technology, 2007, Focal Press, ISBN 13:978-0-2408084-4-4.

Article, Evaluating Emissions of Your New IBOC Transmitter, Radio World Engineering Extra, June 2005.

Article, Posting Hazard Communications Signs at Your Radio Transmission Plant, Radio Guide, April 2005.

Peer-reviewed paper: Interference Potential of Hybrid Digital Transmission: An IBOC Occupied Bandwidth Case Study, NAB-BEC, 2004.

Peer-reviewed paper: Integrating ANSI-Compliant RF Signs into Corporate RF Safety Programs, NAB-BEC 2004.

Peer-reviewed paper, co-author: Applying the Principles of Data Communications to the Development of an Open and Universal IBOC Data Protocol, NAB-BEC 2003.